| Dear Partner,
As you may be aware, the California Consumer Privacy Act (CCPA) will go into effect on January 1, 2020. The CCPA provides California consumers more transparency about how companies collect and use their data, and enables consumers to exercise privacy rights, including the ability to opt-out of a "sale" of personal information as defined under the CCPA. In this email, Smaato will provide you with an overview of our relationship under the CCPA. Your Relationship With Smaato Depending on the type and scope of services that Smaato offers to you under our applicable agreement(s) and the terms of such agreement(s), Smaato may either operate as a "business" or as a "service provider" for the purposes of the CCPA (as such terms are defined under the CCPA). Where you provide personal information of California consumers to Smaato for the standard scope of products and services subject to Smaato's online Terms of Service (SPX) or standard written agreements, such personal information is disclosed to Smaato in Smaato's capacity as a "business". Please note that under your existing agreement(s) with Smaato, you are obligated to comply with applicable laws. This obligation also includes compliance with the CCPA if it applies to you. We also expect and understand that you will provide the required notice to consumers of their rights under the CCPA, including the rights to access, delete, and opt-out of "sales" of personal information. Additionally, we expect and understand that you will implement the "Do Not Sell My Personal Information" link on your digital properties and explain how consumers can exercise the right to opt-out of "sales" of their personal information, such as by enabling "limit ad tracking" through device-level settings.
Please understand that in the course of our own compliance measures we need to reserve the right to review applications and suspend access to our platform if the above requirements are not complied with. Complying With Technical Signals As the IAB CCPA Policy Framework has now been published, we expect our supply partners to implement and pass the IAB's CCPA Compliance Framework technical signals. Until then, we will interpret device-based "limit ad tracking" signals originating from California as also indicating that consumers have opted out of the "sale" of their personal information. When we process personal information of users who have opted out and subject to the terms of our agreement(s) with you, we will act as your "service provider." As such, we will solely process, retain, use, and disclose this personal information (i) for you or on your behalf for business purposes under the CCPA to perform Smaato's obligations under our agreement(s) as updated from time to time and (ii) as permitted for service providers or under a comparable exemption from "sale" under the CCPA. This includes ad delivery, reporting, measurement, security, fraud detection, debugging, as well as improving and developing features for the products we offer you. We believe that the above-mentioned clarifications and updates will have no material adverse impact on you as our partner and, therefore, this email notice serves as clarification on our handling of the personal information that you make available to us under the CCPA. If you have a differing perspective or would like to provide us with a CCPA service provider addendum, please reach out to your Smaato account manager or email us at ccpa@smaato.com. For supply partners where Smaato processes personal information in a restricted manner under our respective individual agreement(s), including where we have already entered into a separate CCPA agreement with you, Smaato will process personal information as your "service provider" as defined and permitted under the CCPA. More Information
For more information, please see our CCPA FAQ post here and the IAB CCPA Framework materials. If you have any questions with respect to this email notice, please contact your Smaato account manager or email us at ccpa@smaato.com.
Best regards,
The Smaato Team | 
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